STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

JEFFREY S. WHITE, District Judge.

WHEREAS, Plaintiffs filed their Consolidated Amended Complaint for Violations of the Federal Securities Laws on August 10, 2010;

WHEREAS, this Court entered an Order on September 16, 2014, staying this case until the conclusion of United States v. Shabudin and Yu;

WHEREAS, this Court entered an Order on April 21, 2015, lifting the stay, referring the parties to Judge Beeler for the purposes of completing a settlement conference by July 21, 2015, and setting a case management conference for July 31, 2015 at 11:00 a.m.;

WHEREAS, the parties have had several telephonic conferences with Judge Beeler, most recently on June 25, 2015;

WHEREAS, the parties have reached an impasse regarding whether certain insurance-related disclosures would be made by Defendants in the course of mediation;

WHEREAS, Plaintiffs have determined that they will file a motion to compel if an agreement regarding the disclosure is not reached;

WHEREAS, Judge Beeler issued a minute order setting an in-person settlement conference to be held after the disclosure issue is resolved (Docket No. 352);

WHEREAS, while the parties were in the process of meeting and conferring regarding Plaintiffs' anticipated motion to compel discovery, the parties made progress negotiating a potential compromise;

WHEREAS, the parties are working to resolve the disclosure issue and believe that issue must be resolved before the parties can have a meaningful settlement conference with Judge Beeler;

WHEREAS, Defendants do not believe resolution of the disclosure issue can be completed in time to hold a settlement conference by July 21, 2015, because the proposed compromise would require consent of non-parties; and

WHEREAS, Plaintiffs will file a motion to compel to resolve the disclosure issue in the event that a satisfactory compromise is not reached.

THEREFORE, IT IS STIPULATED AND AGREED, by and among the parties and their respective counsel of record, that the Case Management Conference in this matter currently scheduled for July 31, 2015, should be continued, and ask that the Court continue the Case Management Conference to November 13, 2015, or as soon thereafter as the Court shall require, to allow additional time for completion of the settlement conference.

[PROPOSED] ORDER

Pursuant to stipulation, and good cause appearing therefore, IT IS HEREBY ORDERED THAT the Case Management Conference scheduled for July 31, 2015, at 11:00 a.m. is continued to Nov. 13, 2015, at 11:00 a.m.

PURSUANT TO STIPULATION, IT IS SO ORDERED.